Cross-border investigations present some of the most complex challenges for retailers with global supply chains, introducing many potential traps for in-house counsel. As US authorities continue to expand their enforcement actions overseas, increasing the civil and criminal exposure for retailers and their leaders and employees, authorities in other countries are expanding this potential liability by increasingly engaging in their own parallel investigations or partnering with US authorities. Meanwhile, data privacy, state secrets, and other regulatory and statutory challenges can complicate a company's ability to respond. In these circumstances, developing and conducting a sophisticated cross-border investigation plan is critical to your defense.

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Originally published Apr 29, 2020.

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